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Tax systems and competitiveness in Central Europe
Zsuzsanna Galántainé Máté1
Abstract
Due to the growth of the globalizational processes not only trading is becoming international
but the investments and the production are showing a global feature through more countries.
All these will eventuate in losing the outlines of the geological units and competitiveness will
show a global feature. The sovereign tax policies cause financial externalities. The diversion
in the countries’ taxation offer the possibility of arbitrage for the mobile productional factors,
which can affect the international capital flow and can influence its direction, size and place.
In consequence of the globalization, also the means and aims of the economic policies are
altering. In the new world economic situation even the role of the states change. The tax
systems cannot create or replace the competitiveness of a country, it can only incentive the
developement of its incividual factors.
Changing roles of states and taxation
Experts approach the subject of competitiveness from different sides, we can talk about
companies’, countries’, regions’ or cities’competitiveness (Lengyel-Rechnitzer 2000).
Hereafter, let’s regard it as a collective noun which means an ability for getting a position in
the market competition (Török 1997) and keeping it for a long time, and it means the
endogenous growth and its factors which can be kept up in the circumstances of global
competition respectively (Porter 1990). The primary function of the taxes is to ensure a
coverage for common expenses. By the fact that a state what, how and to what extent imposes
the taxes influences the income distribution among the economic participants and the usage of
factors of production. Taxation policy affects the economic environment and thus can
influence directly or indirectly the competition and/or the competitiveness.
The direct tax systems which are still working nowadays were developed in the years after
World War II inside a frame of much closer economies than today in which the aim of tax
policies was the domestic economic and social aspects and servicing the budget. Companies
worked and invested their capital in the country where their headquarters were, the
individuals earned their income in their own country. Applying the principle of headquarter
country didn’t mean a problem in the taxing system and it didn’t cause a conflict with the tax
authorities of other countries. When a national tax system was formed other countries’ tax
related actions were not needed to be considered. Those did not affect the local economies’
decisions, the economy’s competitivness and the formation of the national taxbasis.
Due to the rapid growth of the globalizational processes not only trading is becoming
international but the investments and the production are showing a global feature through
more countries, boundaries are disappearing, technological advancement is accelerating,
moving the projects and changing the owners among different regions are becoming more and
more general, and the advancement of communication and transportation is speeding up as
well. All these will eventuate in losing the outlines of the geological units and
competitiveness will show a global feature.
1
College for Modern Business Studies associate professor, SZE University Ph.D student, email: [email protected]
In the new world economic situation even the role of the states change. One of its
contradiction is that (Szentes 2005), on the one hand, a states’ responsibility and task grow
while trying to be competitive nationally and establishing a structural and institutional
accommodation. On the other hand, globalization, integration and the activities of the
transnational companies largely restrict the effectiveness of the national influences on
economic processes and even reduces its possibility. The target-tool systems of the economy
policies are changing and governments have less and less chances to influence international
competition by traditional means (e.g. by export support). The indirect methods come to the
front, which are characteristically directed toward developing those business environment
factors that determine the companies’ competitiveness (Lengyel 2000).
With the incursion of globalization capital market becomes geographically more mobile
which makes tax bases moveable. This gives the opportunity for some countries to create a
more favourable tax environment than other countries have with their tax policy in order to
attract mobile capital (Hetényi 1998). The differences in certain countries’ taxation play more
and more relevant part in the decisions regarding investments and finacial matters, and
become particularly important for taxation concerns when a place of investment has to be
selected. As a result of these procedures a special market comes into being, the countries’
market, which can be called „the market of sovereignty” (Mázsa 2001). The fight for the
investors, workplaces and taxpayers among the countries is placed on a new foundation.
The level and structure of taxation
Because of the historical traditions, different taxing philosophies, the diverse judgement of the
nation’s role, the national economy-policy, and because of the needs and assets of balance
management tax systems have rather different features in certain countries. Looking at the
rates of national reallocation the differences are significant in the world and within the
expanded union as well. The different levels of tax burden can be seen in Figure 1.
Figure 1: Average tax burden of some countries in 2003
tax revenues / GDP %
60
50
40
30
SE DK
BE FR FI AT
SI HU
PL EE
IE SK LV
LT
20
10
0
Source: Eurostat, OECD
EU
OECD
US JP
Studying the features of the EU’s tax load in international comparison, it can be seen that the
tax load is significantly higher comparing to the two developed countries, to USA and Japan,
which can be regarded as „clean market economies”, and this is not only in the relation of the
Scandinavian welfare states of the EU and the „social market economy”but it is true even if
we look at the average of EU-15 or even the EU-25 (Szabó 2004). Looking at the tendency of
the past we can see that the differences are wider now. The level of general tax load was
lower in 2002 in all new member countries than the average of the EU-15. Hungary is
considered to be a country which has higher tax load than the average not only in comparison
with OECD, but with the majority of the similarly developed EU-15 so-called cohesive
countries as well, or even with all the other countries who joined together with us.
In favour of the international competitiveness of the EU, and its member countries - including
our home – it is desired to reduce the level of tax load. To significantly reduce the tax level
coverage must be possessed. Fundamentally this can be insured by the increase of the weight
of GDP, but the cheaper governmental operation can also expedite it largely. The studies
which analized the relation between the countries’ GDP productive skills and taxing level
showed a moderately strong negative correlation between the two factors, id est, they
determined that the level of tax load can be reduced by increasing the weight of GDP (Szabó
2004). This can mainly be reached by increasing significantly the productivity or it can be
expedited by wide-ranging extensive developments.
Taxing narrows those sources that are available for an economic growth. Therefore the
principle of effective taxing expresses an economic requirement which says that the sources
needed for financing common properties must be ensured by disadvancing the growth of an
economy as little as possible (Balogh 2004). The effect of taxing on economic growth can
influence a country’s competitiveness in a wide-ranging contexture.
Beyond the taxburden’s relative level the other essential part is its structure. Looking at the
average of EU indirect taxes play a more important part in the structure of revenue taxes than
in the USA. Indirect taxes provide a bigger amount of revenue tax than the income tax even in
the recently joined countries’ tax structure. On the lower level of income-standard the taxes
on consumption bring more stable budget returns. When the roles of different taxes are
compared we should not ignore the fact that the same tax can have different effects in that
kind of circumstances which a different economic development has (Szabó 2004).
Whether the tax burden is high or low, certain countries can reach good growth results. It is
not the rate of common expenses which is particularly important but its quality and what the
money is spent on and how effective it is. Tax system can not replace the competitiveness of
an economy, in the best case it can only encourage some of its factors’ development.
Some thoughts about tax competition
Both positive and negative elements appear in the general effects of globalization on tax
systems. The tax-collector countries do not like the fact that the capital flow which is freer
than before provides new possibilities for minimalizing payable tax and for avoiding tax. At
the same time, tax competition encourages the states to reduce the taxes of mobile productive
factors themselves in order to win capital. This effort can bring more tax bases for the capital
„luring” country and it can lead to the erosion of the national tax bases in the „abandoned”
country endangering its tax incomes. To do the public duties of a country is still the
governments’s task, their basic interest is to protect their financing sources. To stop the
decrease in tax revenues and or to balance the budget gap caused by national overspending
(within the conditions of tax competition) usually the common liabilities of the less mobile
productive factors, primarily the taxes on labour and consumption, are increased. All these
can lead to the decay of the status of employment and it can damage the tax system. (Mike
2003). According to the common opinion in the literature, when a multinational company
decides where to make investments the most important factor is the general status of the
receiving country’s economy. Depending on the type of the investment the factors that are
measured are the followings: political and economical stability, state of the infrastucture, the
characteristics of human capital (its productivity, qualifications, relative costs), size of the
market, income level, economy-political and regulational environment and institutional
background. The concrete investment-incentive and regulative assets’s role becomes strong
when uniformity can be seen in those above mentioned features that were considered relevant.
(Hassett – Hubbard 1998)
The tax policy which encourages investments is first of all brought up in the less developed
countries therefore its importance is even bigger now that the union is expending toward EastEurope. For the recently joined small countries which have similar characteristics it
seemed/seems an obvious solution to keep up the capital attracting policy by reducing their
rate of tax more. In these provisional economies – in the lack of proper internal sources – the
inflow of foreign active capital is a particularly significant factor in establishing a
maintainable long-term progress, and it can largly contribute to the modernization of these
economies.
Communal harmonization relating to direct taxes is narrow-ranged and does not contain
regulations on neither the tax bases nor the rate of tax so far. The freedom of national tax
systems is rather big, in the course of their regulations only the following must be considered:
it should not contain negative discrimination or an action which might restrict the freedom of
competition, and the union regulations – which are much sticter - in connection with national
supports should be taken into account. Beyond that the member countries should respect the
principle of communal loyalty while exercising tax sovereignty. The possibility for tax
competition is rather wide-ranging. The corporation tax rates show great break-up within the
world and the European Union. The Table 1 shows the different corporate tax rates.
Table 1: Combined corporate income tax rates 2 in 2004 (%)
High rates for example
Japan
United States
Germany
France
Greece, Spain
Netherlands
Belgium, Austria
Sweden
Czech Republic
Portugal
40,9
39,3
38,9
35,4
35,0
34,5
34,0
28,0
28,0
27,5
Low rates for example
Estonia
Poland
Slovakia
Island
Rumania
Hungary
Lithuania
Latvia
Cyprus
Ireland
0 / 24
19,0
19,0
18,0
16,0
16,0
15,0
15,0
10 / 15
12,5
Source: OECD
2
The basic combined central and sub-central (statutory) corporate income tax rate given by the adjusted central
government rate plus sub-central rate.
The increasing tax comptetition is also expressed in the reduction of corporate tax rates. That
can be seen in Table 2.
Table 2: Corporate tax rates
OECD
EU-25
EU-15
Austria
Netherlands
Czech Republic
Finland
Rumania
France
2004
29,70 %
25,75 %
36,80 %
34,00 %
34,50 %
28,00 %
29,00 %
25,00 %
35,40 %
2005
26,49 %
23,29 %
30,10 %
25,00 %
31,50 %
26,00 %
26,00 %
16,00 %
35,00 %
European Union -15
EU New Member – 10
2000
35,3 %
27,4 %
2005
30,1 %
20,6 %
Source: Eurostat
It is important to emphasize that the tax rates themselves do not measure the factual tax
burdens since those are much influenced by the differences of the taxbasis, the different tax
benefits – reliefs, and the levy discipline. Those countries that use higher tax rate refer to the
harmful tax competition and are in favour of determining a minimal tax quote. Since the
collision of interests is very strong a policy for this hasn’t been born yet. In the case of byelaw it can be seen as an international tendency that the tax rates are decreasing and the tax
basis is simultanuously increasing, and the range of benefits is narrowing.
Other correlations between tax systems and competitiveness
Some factors that may influence the companies’s effective tax burden. (FinkenzellerSpengel 2004 and Borsi-Losooncz 2005)
1. On what principle is the taxable income determined? In the Anglo-Saxon practice it is
determined by the tax law, the German model builds upon the data of the accounting
result sheet. In the latter case it is important that how harmonized the financial rules are.
2. Does the fate of the profit influence its taxing? Is there a different tax rate for the withheld
and/or distributed profit? Is there double taxation on the dividend? For example in Estonia
the tax rate of the earnings retained in the business is 0 %, only the distributed profits have
income tax.
3. What is the relation like between the corporate and the personal income tax? Is there a
double taxing at the paid bonus of the individuals? What is the transit like between the
two kinds of tax?
4. Amortization policy. Is there a chance for a rapid depreciational deduction of the tangible
fixed assets? On what conditions can be the amortization rendered at the tax base?
5. Handling losses. With what time restriction can be the loss taken into account? Can the
assign continue the detonation of the predecessor’s loss? Is there a possibility for
recognition of losses carry-back?
6. Tax consolidation. Is there a possibility for taxation on a corporate level for those who
belong to a corporation by combining profit and loss?
7. Reserve evaluating methods. Do the accounting and/or tax legislation prefer any kind of
reserve evaluating system which can influence for example the effect of inflation when the
reserves are accounted?
8. Handling transfer prices. Among the linked companies what tax base corrections must be
accounted for and what kind of documentation is required in the case of prices that differ
from the market?
9. Regulating ownership credit. To what extent can the financing expenses of the ownership
credit be accounted on the charge of the tax base.
10. Rules of accruals, depreciations. What accrual formations are allowed by the tax law and
can the dubious claims be validated at the tax base?
11. Other company tax- and incident burden. What other types and scales of tax burdens do
businesses have?
The consumption taxes are highly harmonized in the EU. In the value added tax the principle
of the country of origin would suit the spirit of a common Europe. The Committee made a
proposal in 1987 for switch-over, however, since there are no appropriate conditions, a
temporary system is being used which prefers the principle of target country. By switching
over to the principle of the country of origin the high product taxes would result a drawback
in competition for the countries using high VAT rate. In this system all the products are sold
in any other member countries like it would be sold at home. The seller uses the tax rate of his
country when he determines the price of his product so in the inner market - among the
products that have the same functions and similar manufacturing cost - that product will be
cheaper and more competitive which comes from a country with lower VAT rate. (Galántainé
2003).
An important requirement of the tax system is the applicability of the rules and its relative
stability in middle-term. The law sources’ complexity, inconsistancy and changeability
makes the economic environment less predictable and spoils the manageability of the
economy. The complicated tax administration and the increasing supervision mean an
additional burden both on the business world and on the tax authorities, and it provides a
favourable land to avoid paying taxes.
Tax system plays a rather big role in how big the rate of the hidden economy, which is not a
by-issue in judging a country internationally. Especially the strong taxes on the less mobile
working incomes and consumption can lead to the growth of the black economy, which is
actually an inland form of avoiding taxation (Hetényi 1998). In addition, this phenomenon
retroacts on taxing, and the taxpayers’ tax burden will increase because of the disappeared and
lost tax bases. By „whitening” the economy and improving the tax morals revenue taxes can
be increased.
Appendix
Country abbreviations
BE
CZ
DK
EE
GR
ES
FR
IE
IT
CY
LV
LT
LU
Belgium
Czech Republic
Denmark
Estonia
Greece
Spain
France
Ireland
Italy
Cyprus
Latvia
Lithuania
Luxembourg
HU
MT
NL
PL
PT
SI
SK
FI
SE
UK
JP
US
NMS
Hungary
Malta
Netherlands
Poland
Portugal
Slovenia
Slovakia
Finland
Sweden
United Kingdom
Japan
United States
New Member States
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